Major Hazard Facilities - Safety Management Systems _presentation_

Major Hazard Facilities
Safety Management Systems
Overview
The seminar has been developed to provide:
• Context with MHF Regulations
• An overview of what is required
• An understanding of the SMS and why it is important
2
Some Abbreviations & Terms
• AFAP - As far as (reasonably) practicable
• Employer - Employer who has management control of the facility
• ER or ERP - Emergency response or Emergency response plan
• Facility - any building or structure at which Schedule 9 materials are
present or likely to be present for any purpose
• HAZID - Hazard identification
• HSR - Health and safety representative
• LOC - Loss of containment
• LOPA – Layers of protection analysis
• MA - Major accident
• MHF - Major hazard facility
• MOC – Management of change
• OHS - Occupational health & safety
• SR - Safety report
• SMS - Safety management system
3
Topics covered in This Presentation
• Introduction
• Regulations
• What is a safety management system?
• SMS models and standards
• Key elements of the SMS
• The importance of SMS
• What should the SMS do?
• Measurement of performance
• Examples of SMS performance standards
• Emergency planning
• SMS testing
• Items to note
• Critical success factors
• Sources of additional information
4
Regulations
Occupational Health and Safety (Safety Standards) Regulations 1994
5
What is a Safety Management System?
• An SMS is a comprehensive and integrated system that
ensures that all work at the facility is conducted safely
• It should be fully documented, accessible and
comprehensible to those that need to use it
• It recognises the potential for errors and establishes robust
defences (control measures) which are fully implemented, to
ensure that errors do not result in accidents or near misses
• It is comprises a set of work practices and procedures for
monitoring and improving the safety and health of all aspects
of the operation
6
Key Terms Used in Describing the SMS
Comprehensive
• Describes the way that all safety issues including control
measures are managed
• Clear link between controls management and the SMS
Integrated
• The structure is logical, systematic
• Logically ties in to other management systems
• Corporate systems do not contradict onsite systems
Comprehensible
• Abbreviations and terms used mean something to employees
• Consideration of language issues
7
Key Terms Used in Describing the SMS
Implemented
• Procedures are approved and in circulation
• Evidence is available – completed forms and/or checklists
• Employees are trained and knowledgeable
Accessible
• Employees are aware of how to obtain the most up to date or
relevant procedures
• Employees can obtain the SMS information needed to support
control measures
8
SMS Models & Standards
• Sound management systems are all similar in fundamental
terms
• Compliance with the MHF Regulations does not require any
particular standard to be used, nor will compliance with an
existing management standard ensure compliance with the SMS
requirements of the MHF Regulations
• There are a variety of ways in which the SMS can be structured.
Most large organisations will have their own structure already
• However, adoption of a proven standard may assist an MHF
employer
9
Examples of SMS
OH&S Management Systems Model – AS 4801
Overall
vision, goals
and
commitment
to improve
• Legal compliance
 Suitable, adequate, • Objectives and targets
effective • Implementation plans
 Changes needed?
 Opportunities to
improve?
• Resources
• Leadership responsibility
• Monitoring and • Training and competency
measurement • Consultation and communication
• Incident investigation • Documentation
• Records management • Hazard identif ication, risk assessment
• Audits and controls
• Emergency response
10
Examples of SMS
ISO 14001 Environmental Management Systems
Environmental
Policy
Planning
Implementation
& Operation
Checking &
Corrective Actions
Management
Review
11
Key Elements of the SMS
Policy
Planning
From the previous
examples, there are
common elements
Implementing
Assessing
Management
Review
12
Key Elements of the SMS
Policy
Effective health and
Planning safety policies set a
clear direction for the
organisation to follow
Implementing
Assessing
Management
Review
13
Key Elements of the SMS
Policy
Planning An effective management
structure and arrangements
are in place for delivering
Implementing the policy.
There is a planned and
Assessing systematic approach to
implementing the health
and safety policy
Management
Review
14
Key Elements of the SMS
Policy
The policies and
Planning procedures are put in
place to manage all
aspects of the control
Implementing measures that ensure safe
operation of the facility
Assessing
Management
Review
15
Key Elements of the SMS
Policy
Planning
Performance is
measured against
Implementing agreed standards to
reveal when and where
improvement is needed.
Assessing
Management
Review
16
Key Elements of the SMS
Policy
Planning
The organisation learns
Implementing from all relevant
experience and applies
the lessons.
Assessing
Management
Review
17
The Importance of SMS
• In reviews of accidents, a common thread throughout is the
inadequacy of management systems that might have
prevented the accident from occurring
• Examples of some issues identified are
– Lack of hazard review and risk assessment to predict and
prevent incidents
– Insufficient investigation and follow up after previous incidents
– Inadequate training of staff
– Failure to implement effective mechanical integrity programs
18
The Importance of SMS
The following information provides broad details on some US
incidents and contributing causes
19
The Importance of SMS
Breakdown of management system categories identified as
contributing causes in incident investigations
20
The Importance of SMS
• Flixborough 1974
– Management of
modification failure
– Inadequate experience
– Overstretched resources
• Piper Alpha 1988
– Failures in shift handover
– Permit to work
– Training
– Communications
– Auditing
21
The Importance of SMS
• Pasadena 1989
– Maintenance
– Permit to work errors
– Failure to follow-up on
audits
• Longford 1998
– Inadequate knowledge of
hazards
– Absent personnel
– Poor procedures
22
The Importance of SMS
BP America Refinery Explosion Texas City, 23 March 2005
• Corporate safety oversight,
including the safe
management of sites obtained
through mergers and
acquisitions
• Corporate safety culture
• Corporate and site SMS
• Near miss reporting and
investigation programs
• Mechanical integrity programs
• Hazard analysis programs
• Change management
23
The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
• In the early hours on
Sunday a number of
explosions occurred at
Buncefield Oil Storage
Depot, Hemel Hempstead,
Hertfordshire
• At least one of the initial
explosions was of massive
proportions and there was a
large fire, which engulfed a
high proportion of the site
• Over 40 people were
injured; fortunately there
were no fatalities
24
The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
What control measures
• Were in place?
• Could have been in place?
• Were they effective?
25
The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
Common theme – failure to manage the control measures
26
The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
• What SMS elements were needed to ensure that the control
measures worked when required?
27
The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
28
The Importance of SMS – Australian Experience
• Feedback from regulator site visits to Australian MHFs,
together with examination of incident data has revealed the
following issues are likely to be the weakest links within an
SMS
– Management of 3rd parties
– Maintenance procedures and systems
– Hazard identification and analysis
– Engineering design and review
– Operating procedures
– Management of change
29
The Importance of SMS – Australian Experience
Other issues to note:
• There are always fundamental failings in the “system”
• Complacency and safety versus production conflicts
• Deficiencies in practice with adherence to application of the
SMS rather than system standards
• Failure to accept and prepare for emergencies
30
What Should the SMS Do?
• The SMS is the tool with which the Employer meets the overall goal
of the Regulations
• The SMS should cover the following
– Define safety roles and responsibilities
– Ensure adequate skills, information, tools and decision-making are
present in day to day and abnormal operations
– Maintain awareness of hazards and risks
– Plan, implement, measure and evaluate MA controls and the SMS
– Develop performance requirements
– Set targets for improvement of safety at the facility
– Manage change
31
What Should the SMS Do?
• Manage and maintain knowledge
• Instigate HAZID and risk assessments
• Manage adequate human resources
• Provide performance information to all levels of
organisation
• Review and improve the SMS itself
32
What Should the SMS Do?
• Manage safe operation at the facility, including MAs,
specifically focusing on:
– Prevention
– Reduction
– Mitigation
• It is not just documentation - it is the actual implementation
of processes, procedures and practices at the facility
• Include and reflect the safety culture at the workplace
33
What Should the SMS Do?
• Some companies, in particular employers of multiple sites, may
apply corporate standards for an SMS
• These may prescribe the entire SMS, or only common high-level
components such as the overall policies and procedures
• In other cases corporate SMS requirements may be very
limited, and the site will then need to develop its own systems
34
What Should the SMS Do?
• Many corporate systems specify that local regulations override
corporate requirements if they are more stringent
• Other companies may employ integrated management
systems for the business as a whole
• It is entirely up to the Employer to choose how the SMS is
structured and developed
• However, in all cases the SMS must provide a management
focus on the specific control measures required for safe
operation of the particular facility
35
What Should the SMS Do?
Level 1 Corporate Safety Management System
Level 2 Local procedures and practices (design, maintenance & operation)
Consequences
Hazards
Accidents
Causes
Level 3
Prevention Mitigation
MA Potential
Controls Controls
36
What Should the SMS Do?
• The SMS should not just be seen as satisfying MHF
requirements
• It should be used as a performance management tool to assist
in managing the entire operation, including other performance
based regulatory requirements
• Most modern management system “standards” or "models"
feature a set of generic elements, forming a continual
improvement cycle
37
Measurement of Performance
• Performance standards/indicators must be developed and
implemented as part of the SMS (e.g. measure the
effectiveness of SMS) to support the MHF safety objectives
• The following principles apply in defining performance
standards: Make them SMART
• Specific
• Measurable
• Achievable
• Realistic
• Targeted
• The purpose of performance standards/indicators for the SMS
is to enable the objective measurement of its target and
(subsequently) effective maintenance and improvement of
performance
38
Measurement of Performance
• Standards and systems need to be practical
• Should not place an unworkable burden on employees
• Ensure open, comprehensive and accurate reporting of errors or
problems
Is an absence of evidence of problems really indicating
high performance?
39
Measurement of Performance
• Performance indicators need to be meaningful and contribute to
the overall evaluation of the SMS effectiveness
• If a control is stated to be in place for prevention of an MA,
then:
– Is it implemented?
– Is it effective?
– Is it audited?
– Are the results used for improving the effectiveness of controls
management?
40
Measurement of Performance
• Performance indicators should be established covering (as a
minimum):
– How often audits are to be undertaken
– Scope of the audits
– Are the controls implemented?
– Are the controls functional?
– % compliance, partial compliance and non compliance
• Performance indicators should be sufficiently detailed and
transparent to enable the effectiveness of the SMS to be
apparent from the documentation
41
Measurement of Performance
• The audits need to be evaluated against criteria developed by
the MHF
• They should include steps to continually improve the SMS, so
there needs to be processes and measures designed to
identify and implement improvements to the system itself
• Three main types of audits
– First audit: Self audit
– Second party: audit of suppliers
– 3rd party: external agencies e.g. regulator, certification bodies.
42
Measurement of Performance
• Likewise, 100% compliance is a desirable objective - but realistically
not practical
• Setting a tiered acceptability criteria could be an option
Example only:
Item Compliance Partial Non-
Compliance compliance
Audit frequency 90% 10% 0%
for controls met
Audit time frame 90% 10% 0%
achieved
Controls 100% 0% 0%
implemented
Controls 95% 5% 0%
functional
43
Examples of SMS Performance Indicators
Permit to work Number of accidents or near misses caused by a
failure of this system
% permits audited compliant with procedure
Management of change Number of accidents or near misses caused by a
failure of this system
% of MoC forms completed in compliance with
procedures
% temporary changes beyond their time limit
Operating procedures % of new procedures completed
% of procedures reviewed
Auditing % audits completed to schedule
Number of non conformances closed out/month
44
Items to Note - Emergency Planning
• The MHF must prepare an emergency plan addressing the on-
site/off-site consequences
• Must consult with employees and emergency services
• Plan should consider
– Accident type (e.g. major/minor, environmental, personal safety,
on-site, off-site, property damage)
– Command hierarchy and contact information
– Equipment required
– Contingency plans
• Plan should be tested, reviewed, updated
45
Items to Note - Management of Change
• Management of change needs to be considered very carefully
within the safety report
• An issue often discussed is:
– When is a change really a change?
– When is a change not a change?
46
Items to Note - When is a change really a change?
• Any change to an MHF needs to be evaluated in the context of
the safety report
• Examples of this include but are not limited to:
– Organisational change
– Addition of a new unit
– Closure of a unit
– Any modification to a potential MA
• Desired Outcome: Demonstrate that at least the same level of
risk or lower is achieved after the change and that all the
processes within the safety report are followed and transparent
47
Items to Note - When is a change not a change?
• Any change to an MHF that involves swapping like for like is
not considered to be a change
• This assumes the equipment or systems being changed are fit
for purpose
48
Items to Note - Incident Investigations
• Incidents that occur or could have occurred at an MHF are a
valuable source of information
• As with good practice, all incidents at a facility should be
reviewed for lessons learned and their findings implemented
for prevention in the future
• For an MHF, investigation of MAs is of particular importance as
it will provide insight into the mechanism of occurrence
49
SMS - Critical Success Factors
• Adequate resources for both development and improvement
• Personnel are aware of their responsibility and accountability
• Personnel are trained/competent
• Consistent with the understanding of risk gained from the risk
assessment
• There should be sufficient focus on MAs, from planning
through to operations
• The Employer must document the basis for the facility's SMS,
and the SMS itself
50
SMS – Critical Success Factors
Comprehensive and Integrated
• Adequate resources for both development and improvement
• Responsibilities & accountabilities defined
• Adequate education and training is provided for employees
• Covers the whole facility as defined in the safety report
• Employees know how to access it and understand it
• Performance indicators & standards for the control measures and
the SMS as a whole are defined
• Planning, implementation and monitoring processes are provided
for control measures and the system as a whole and failures are
addressed
• Processes are provided for review and revision of control
measures and the SMS
 More information is available in Booklet 3 on the SMS
51
Review and Revision
• The SMS needs to be reviewed on a regular basis to ensure it
is fit for purpose for management of an MHF
• Over a period of time the lessons learned together with results
of performance reviews should enable improvements to be
documented
52
Sources of Additional Information
• Safety Management, Hazardous Industry Planning Advisory
Paper No. 9, Guidelines for the Development of Safety
Management Systems, Department of Urban Affairs and
Planning, 1995
• AS/NZS 4801:2001, Occupational Health and Safety
Management Systems
– Specification with Guidance for Use, Standards Australia,15
November 2001
– General Guidelines on Principles, Systems and Supporting
Techniques, Standards Australia,15 November 2000
53
Sources of Additional Information
• AS/NZ ISO 9001:2000, Quality Management Systems
• AS/NZ ISO 14001:2004, Environmental Management
Systems
• API Recommended Practice 750, Management of Process
Hazards
• API Publication 9100, Model Environmental Health and Safety
Management System and Guidance
54
Sources of Additional Information
• UK Health and Safety Executive HSG65, Successful Health and
Safety Management
• US Department of Labour. OSHA Standard CFR 29 1910.119,
Process Safety Management
• AIChE, CCPS, Guidelines for Implementing Process Safety
Management Systems
• Management System Failures Identified in Incidents
Investigated by the U.S. Chemical Safety and Hazard
Investigation Board, Angela S Blair PE Chemical Incident
Investigator, Process Safety Progress, December 2004,
Volume 23, No.4
55
Questions?
56